190 PAKISTAN CONST. art. 45. That portion states that “[t]he President shall have power to grant pardon, reprieve and respite, and to remit, suspend or commute any sentence passed by any court, tribunal or other authority.” Id. 191 Hasnaat Malik, Over 350 Death Row Prisoners Hanged Since Dec 2014, Govt Informs SC, TRIBUNE (Mar. 22, 2016), http://tribune.com.pk/story/1070486/over-350-death-row-prisoners-hanged-since-dec-2014-govt-informs-sc. 192 President of the Islamic Republic of Pakistan, Grant of Special Remmission Under Article 45 to Juvenile Condemned Prisoners, (13 December 2001) 193 Ziaullah v. Najibullah, PLD 2003 SC 656 194 Government of the Punjab Home Department, Grant of Special Remission Under Article 45 of the Constitution to Juvenile Condemned Prisoners, (Aug. 18, 2003). 195 In Islamic criminal law, ta'zir refers to offenses for which the Quran does not specify a fixed punishment, as it does for hudud crimes. As such, ta'zir punishments are sometimes referred to as “discretionary” punishments because they are decided by judges rather than being predetermined by the Quran. Another important difference between hudud and ta'zir punishments is that the former are subject to more stringent evidentiary requirements. 196 Hakim Khan v. Government of Pakistan, PLD 1992 SC 595. 197 Shah Hussain vs. The State, PLD 2009 SC 460. 198 FIDH, Slow March, supra note , at 32. 199 Id. 200 Anti-Terrorism Act of 1997 (XXVI of 1997) § 21(F). 201 JPP & Reprieve, Terror on Death Row, supra note , at 18. 202 The Terror on Death Row Report also describes the case of Zafar Iqbal, who similarly received a pardon for one of his two death sentences, but remains on death row because of an ATA provision purporting to “suspend” a mercy provision that is mandated by Sharia law. Id. at 9. 203 Convention on the Rights of the Child, U.N. Doc. A/RES/44/25, art. 37(a) (1989) [hereinafter CRC]. 204 ICCPR, art. 6(5). 205 Quinnipiac University School of Law Civil Justice Clinic & Allard K. Lowenstein International Human Rights Clinic, Youth Matters: A Second Look For Connecticut's Children Serving Long Prison Sentences, at 3 (Mar. 2013), https://www.law.yale.edu/system/files/documents/pdf/YouthMatters2013.pdf. 206 Id. 207 Human Rights Comm., General Comment No. 32, supra note , ¶ 42. 208 Id. ¶ 42-43. 209 Quinnipiac University School of Law Civil Justice Clinic & Allard K. Lowenstein International Human Rights Clinic, Youth Matters: A Second Look For Connecticut's Children Serving Long Prison Sentences, at 1 (Mar. 2013) https://www.law.yale.edu/system/files/documents/pdf/YouthMatters2013.pdf. 210 ICCPR, art. 14(4). 211 ICCPR, art. 10(2)(b). In Thomas v Jamaica, the detention of the defendant from the ages of 15 to 17 with adult prisoners violated article 10(2)(b) and (3). U.N. Doc. CCPR/C/49/D/321/1988 (1993). 212 Human Rights Comm., General Comment No. 32, supra note , ¶ 42. 213 CRC, art. 37©. 214 CRC, art. 37(d). A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 53